Whether a court's decision in wrongfully denying a peremptory challenge requires an automatic reversal of the related conviction.
This case concerns the effect of an erroneous denial of a criminal defendant's peremptory challenge to a prospective juror who was later seated. Defendant Rivera exercised a peremptory challenge to exclude Ms. Gomez, who worked administratively in a hospital known for treating gunshot victims. The trial judge denied the peremptory challenge, claiming a Batson violation. Ms. Gomez was seated on the jury, which then convicted Rivera of first degree murder in a gang related shooting. The Supreme Court of Illinois held that the judge committed harmless-error in denying this peremptory challenge. Upon appeal before the Supreme Court, Rivera argues that the erroneous denial of a peremptory challenge necessitates automatic reversal "because it undermines the trial structure for preserving the constitutional right to due process and an impartial jury." The State of Illinois, on the other hand, argues that there has been no constitutional violation, and that state law should determine the effect of an erroneous denial of a peremptory challenge on the verdict.
Questions as Framed for the Court by the Parties
Does the erroneous denial of a criminal defendant's peremptory challenge that resulted in the challenged juror being seated require automatic reversal of a conviction because it undermines the trial structure for preserving the constitutional right to due process and an impartial jury?
In 1998, sixteen-year old Marcus Lee was fatally shot. See , Illinois at 1. Respondent the State of Illinois ("the State") charged Petitioner Michael Rivera with first degree murder. See The State alleged that Rivera, an alleged gang enforcer, murdered Lee because of an erroneous belief that Lee belonged to a rival gang. See , Michael Rivera at 3.